ML17262A229
| ML17262A229 | |
| Person / Time | |
|---|---|
| Site: | Ginna  |
| Issue date: | 10/24/1990 |
| From: | Mecredy R ROCHESTER GAS & ELECTRIC CORP. |
| To: | Martin T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| References | |
| NUDOCS 9011130321 | |
| Download: ML17262A229 (10) | |
Text
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89 EAST AVENUE, ROCHESTER N. Y. 14649-0001 TELEPHOkE AREA CODE 716 546'2700 October 24, 1990 Mr. Thomas T. Martin Regional Administrator U.S. Nuclear Regulatory Commission Region 1
475-Allendale Road King of Prussia, PA 19406
Subject:
Inspection No. 50-244/90-18 R.E.
Ginna Nuclear Power Plant
Dear Mr. Martin:
As a result of the inspection conducted on July 19,
- 1990, by a
representative of the South Carol'ina Department of Health and Environmental
- Control, of a
shipment of licensed material, sent from RG&E on July 13,
- 1990, and in accordance with the NRC
'nforcement
- Policy, 10 CFR Part 2, Appendix C (1990), the following violation.was identified.
10 CFR 20.301(a) states that no licensee shall dispose of licensed material except by transfer to an authorized recipient as provided in the regulations in Parts 30, 40, 60, 61, 70 or 72, whichever may be applicable.
- states, in part, that before transferring byproduct material to a specific licensee of the Commission or an Agreement
- State, the licensee transferring the material shall verify that the transferee's license authorizes the receipt of the type, form, and quantity of byproduct material to be transferred.
Condition 60 of the State of South Carolina (an Agreement State)
License Number
- 097, issued to Chem, Nuclear
- Systems, Inc., for the operation of the Barnwell Disposal Site
- states, in part, that loose radioactive waste within shipping casks is prohibited.
10 CFR 61.56 states the minimum requirements for all classes of waste to facilitate handling at a disposal site, and specifically requires in 10 CFR 61.56(b)(1),
that waste must have structural stability which can be provided by the waste form itself, proces-sing the waste to a stable form, or placing the waste in a disposal container or structure that provides stability after disposal.
October 24, 1990 Page 2
Contrary to the above, on July 13,
- 1990, the licensee shipped a
cask containing a disposal container of dewatered spent resin from their facility to Barnwell, South Carolina for disposal in a configuration that did not provide for structural stability after
- disposal, in that the cask contained some loose 'resins outside the disposal container but'within the shipping cask.
We concur with the violation except as noted below.
Corrective Actions:
As a result of radioactive waste shipment number '0790-117 not meeting Condition 560 of the South Carolina License Number 097, Rochester Gas and Electric has initiated a
Human Performance Enhancement, System evaluation for the transfer and shipment of resins.
Prior to the next transfer and subsecpent shipment of
- resin, the following changes are being initiated and will be completed.
1)
Establish personnel training and experience requirements, and ensure personnel responsible for the transfer meet those requirements.
2)
Utilize an improved resin transfer system at the cask to minimize the potential for'plattering and contamination spread during the transfer.
3)
Through procedural
- upgrades, ensure management has been properly notified of any unusual occurrences or potential problems with resin transfers and 'shipments.
4)
Ensure the pre-job briefing for resin transfer and shipment covers the changes listed above.
Date When full Com liance Will Be Achieved The above actions will ensure RG&E is in full compliance with applicable state and federal regulations for all future resin shipments.
RG&E believes that the Severity Level ZIZ classification is inappropriate for the following reasons:
NRC's Enforcement Policy (10 CFR Part 2, Appendix C), states that "the severity level of a violation will be characterized at the level best suited to the significance of the particular violation".
NRC's Enforcement Manual Section 3.5.21 indicates that "signi-ficance" consists of two elements:
technical safety significance
,and regulatory significance.
- Moreover, the Enforcement Manual states that "consideration should be given to the matter as a
whole in light of the circumstances surrounding the violation".
October 24, 1990 Page 3
There are several factors which combine to demonstrate the low significance 'of this incident.
First, the amount of contamination identified outside the inner container was small.
Although smear results indicated that contamination levels exceeded 50, 000 dpm/100 cm, this level was present only at a few specif ic hot
.spots representing a very small percentage of the surface area.
The remaining surface of the inner container was within appropriate contamination limits.
Furthermore, the resin beads found outside of the inner container were few in number.
- Second, the smear results and direct radiation surveys conducted in preparation of the shipment were performed in conformance with RG&E procedures, standard industry practice and ongoing efforts to keep personnel exposure ALARA.
The results of these evaluations did not indicate contamination beyond acceptable limits.
Third, there was no actual or potential exposure to the general public.
All of the contamination was confined to the inside of the shipping cask.
Contamination was only identifiable after the shipment had arrived at
- Barnwel1, South Carolina and was being surveyed within a controlled area.
- Fourth, RG&E's root cause analysis shows the incident to be a
result of isolated personnel error.
This is supported by NRC's statements concerning our "good past performance".
- Finally, when viewed against other enforcement actions of a
similar nature, this incident is less significant and does not warrant the same enforcement treatment.
For
- example, another recent NRC Region I case (i.e.
EA 90-111) involving a transporta-tion incident was also categorized at Severity Level III.
- However, when compared against that case, the RG&E case has much less safety significance.
Specifically, case EA 90-111 involved a spill of radioactive water resulting in contamination of the surrounding area and equipment.
The amount of water remaining in the cask (i.e.
approximately 196 gallons) was 404 of the total cask volume and had a near contact dose rate of 5 mR/hr.
The NRC stated in its Notice of Violation that "adequate management and procedural controls were not in place to ensure that the cask was properly dewatered and dried".
Furthermore, the NRC noted a
concern that the licensee's enforcement history indicated a
declining trend in adequate handling of radioactive waste ship-ments.
As discussed
- above, many of these elements either did not exist on the RG&E incident or were of a lesser significance.
Based on the above factors, RG&E believes that the incident shows a low level of both technical safety significance and regulatory significance
- and, thus, is more appropriately categorized as Severity Level IV per 10 CFR 2, Appendix C, IX, Supplement IV; D-5.'ery truly yours, Robert C.
cre y
ACCELERATED DISTRIBUTION DEMONSTRATION SYSTEM REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)
CCESSION NBR:9011130321 DOC.DATE: 90/10/24 NOTARIZED: NO DOCKET FACIL:50-244 Robert Emmet Ginna Nuclear Plant, Unit 1, Rochester G
05000244 AUTH.NAME AUTHOR AFFILIATION MECREDY,R.C.
Rochester Gas
& Electric Corp.
RECIP.NAME RECIPIENT AFFILIATION MARTIN,T.T.
Region 1 (Post 820201)
SUBJECT:
Responds to violation noted in Insp Rept 50-244/90-18.
DISTRIBUTION CODE:
IE01D COPIES RECEIVED:LTR
(
ENCL SIZE:
TITLE: General (50 Dkt)-Insp Rept/Notice of Vi&o ation Response NOTES:License Exp date in accordance with 10CFR2,2.109(9/19/72).
05000244
/
RECIPIENT ID CODE/NAME PD1-3 PD REG FXL TERNAL: NRC PDR INTERNAL: AEOD AEOD/TPAB NRR MORISSEAU,D NRR/DLPQ/LPEB10 NRR/DRIS/DIR NRR/PMAS/ILRB12 O
E 02 COPIES LTTR ENCL 1
1 1
1 2
2 1
1 1
1 1
1 1
1 1
1 1
1 RECIPIENT ID CODE/NAME JOHNSON,A AEOD/DEIIB DEDRO NRR SHANKMAN,S NRR/DREP/PEPB9D NRR/DST/DIR 8E2 NUDOCS-ABSTRACT OGC/HDS2 RGN1 FILE 01 NSIC COPIES LTTR ENCL 1
1 1
1 1
1 1
1 1
1 1
1 1
1 1
1 1
1 1
1 D
D D
NOTE TO ALL"RIDS" RECIPIENTS:
A D
D PLEASE HELP US TO REDUCE iVASTE! CONTAC!'HE DOCUMENT CONTROL DESK, ROOM Pl-37 (EXT. 20079) TO ELIMINATEYOUR NAME FROM DISTRIBUTION LISTS FOR DOCUMENTS YOU DON'T NEED!
TOTAL NUMBER OF COPIES REQUIRED:
LTTR 21 ENCL 21
rr'ff'WfZIZkf,ggZPÃlrfff'OCHESTER GAS AND ELECTRIC ROBERT C. MECREDY Vice Prerldenl Clnna Nucle61 Producdon I
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69 EAST AIIENVE ROCHESTER N K.14649 0-001 +l TELEPHONE AREA CODE 716 646 2700 October 24, 1990 Mr. Thomas T. Martin Regional Administrator U.S. Nuclear Regulatory Commission Region 1
475 Allendale Road King of Prussia, PA 19406
Subject:
Inspection No. 50-244/90-18 R.E. Ginna Nuclear Power Plant
Dear Mr. Martin:
As a result of the inspection conducted on July 19,
- 1990, by a
representative of the South Carolina Department of Health and Environmental
- Control, of a
shipment of licensed material sent from RG&E on July 13,
- 1990, and in accordance with the NRC Enforcement Policy, 10 CFR Part 2, Appendix C (1990), the following violation was identified.
10 CFR 20.301(a) states that no licensee shall dispose of licensed material except by transfer to an authorized recipient as provided in the regulations in Parts 30 406 606 616 70 or 72, whichever may be applicable.
- states, in part, that before transferring byproduct material to a specific licensee of the Commission or an Agreement
- State, the licensee transferring the material shall verify'hat the transferee's license authorizes.
the receipt of the type, form, and quantity of byproduct material to be transferred.
Condition 60 of the State of South Carolina (an Agreement State)
License Number
- 097, issued to Chem Nuclear
- Systems, Inc., for the operation of the Barnwell Disposal Site
- states, in part, that loose radioactive waste within shipping casks is prohibited.
10 CFR 61.56 states the minimum requirements for all classes of waste to facilitate handling at a disposal site, and specifically requires in 10 CFR 61.56(b)(l), that waste must have structural stability which can be provided by the waste form itself, proces-sing the waste to a stable form, or placing the waste in a disposal container or structure that provides stability after disposal.
October 24, 1990 Page 2
Contrary to the above, on July 13,
- 1990, the licensee shipped a
cask containing a disposal container of dewatered spent resin from their facility to Barnwell, South Carolina for disposal in a configuration that did not provide for structural stability after
- disposal, in that the cask contained some loose resins outside the disposal container.but within the shipping cask.
We concur with the violation except as noted below.
Corrective Actions:
As a result of radioactive waste shipment number 0790-117 not meeting Condition 560 of the South Carolina License Number
- 097, Rochester Gas and Electric has initiated a
Human Performance Enhancement System evaluation for the transfer and shipment of resins.
Prior to the next transfer and subsequent shipment of
- resin, the following changes are being initiated and will be completed.
1)
Establish personnel training and experience recpxirements, and ensure personnel responsible for the transfer meet those requirements.
2)
Utilize an improved resin transfer system at the cask to minimize the potential for splattering and contamination spread during the transfer.
3)
Through procedural
- upgrades, ensure management has been properly notified of any unusual occurrences or potential problems with resin transfers and shipments.
4)
Ensure the pre-)ob briefing for resin transfer and shipment covers the changes listed above.
Date When full Com liance Will Be Achieved:
The above actions will ensure RG6E is in full compliance with applicable state and federal regulations
'for all future resin shipments.
RG&E believes that the Severity Level III classification is inappropriate for the following reasons:
NRC's Enforcement Policy (10 CFR Part 2( Appendix C), states that "the severity level of a violation will be characterized at the level best suited to the significance of the particular violation".
NRC's Enforcement Manual Section 3.5.21 indicates that "signi-ficance" consists of two elements:
technical safety significance and regulatory significance.
- Moreover, the Enforcement Manual states that "consideration should be given to the matter as a
whole in light of the circumstances surrounding the violation".
October 24, 1990 Page 3
There are several factors which combine to demonstrate the low significance of this incident.
First, the amount of contamination identified outside the inner container was small.
Although smear results indicated that.
contamination levels exceeded 50,000 dpm/100 cm, this level was present only at a few specif ic hot spots representing a very small percentage of the surface area.
The remaining surface of the inner container was within appropriate contamination limits.
Furthermore, the resin beads found outside of the inner container were few in number.
- Second, the smear results and direct radiation surveys conducted in preparation of the shipment were performed in conformance with RG&E procedures, standard industry practice and ongoing efforts to keep personnel exposure ALARA., The results of these evaluations did not indicate contamination beyond acceptable limits.
Third, there was no actual or potential exposure to the general public.
All of -the contamination was confined to the inside. of the shipping cask.
Contamination was only identifiable after the shipment had arrived at Barnwell, South Carolina and was being surveyed within a controlled area.
- Fourth, RG&E's root cause analysis shows the incident to be a
result of isolated personnel error..
This is supported by NRC's statements concerning our "good past performance".
- Finally, when viewed against other enforcement actions of a
similar nature, this incident is less significant and does not warrant the same enforcement, treatment.
For
- example, another recent NRC Region I case (i.e.
EA 90-111) involving a transporta-tion incident was also categorized.
- However, when compared against that case, the RG&E case has much less safety significance.
Specifically, case EA 90-111 involved a spill of radioactive water resulting in contamination of the surrounding area and equipment.
The amount of water remaining in the cask (i.e.
approximately 196 gallons) was 404 of the total cask-volume and had a near contact dose rate of 5 mR/hr.
The NRC stated in its Notice of Violation that
<<adequate management and procedural controls were not in place, to ensure that the cask was properly dewatered and dried".
Furthermore, the NRC noted a
concern that the licensee's enforcement history indicated a
declining trend in adequate handling of radioactive waste ship-ments.
As discussed
- above, many of these elements either did not exist on the RG&E incident or. were of a lesser significance.
Based on the above factors, RG&E believes that the incident shows a low level of both technical safety significance and regulatory significance
- and, thus, is more appropriately categorized as Severity Level IV per 10 CFR 2, Appendix C, IX, Supplement IV; D-5.
Very truly yours, Robert C.
credy